About
When your primary customer is the federal government, there are no "minor" compliance concerns.
In the face of increased enforcement activity, as well as mounting Pentagon and congressional scrutiny, industry compliance-robust, effective compliance-matters more than ever. In a contentious national environment over sharply increased defense spending for the war in Iraq, it can help insulate your company against media and public criticism of DoD procurement practices. In addition, post 9/11, the heightened focus on security and anti-terrorism measures makes effective compliance a matter of national concern.
But the relevant regulations and statutes intersect in myriad, unexpected ways, as does their enforcement. Multiple agencies with conflicting priorities are involved and lines of jurisdiction are often blurred. Interpretative guidance from the policy makers often leaves you with few resources for figuring out how to best comply. Equally troubling enforcement "wildcatting" often means that an investigation of an export controls violation by one agency may lead to an FCPA investigation by another, and vice versa.
This makes devising an integrated approach to your company's compliance efforts vital. Failure to do so could come at a cost: damage to your company's reputation, diminished share value and potential exposure to significant civil and criminal penalties.
Contents & Contributors
U.S. EXPORT CONTROLS – THE REQUIREMENTS, REVIEWS, REALITIES AND MYTHS
Joyce Remington, BAE Systems North America
GLOBAL BUSINESS AND THE CHALLENGES OF ITAR COMPLIANCE
Christopher Wall, Pillsbury Winthrop LLP
EXPORT CONTROLS ENFORCEMENT: CONDUCTING INTERNAL INVESTIGATIONS AND RESPONDING TO VIOLATIONS
Peter Jordan, United Technologies Corporation
MANAGING RISKS IN DEALINGS WITH THE OFFICE OF DEFENSE TRADE CONTROLS COMPLIANCE U.S. DEPARTMENT OF STATE
Philip Rhoads, Attorney at Law
MANAGING FCPA COMPLIANCE: SAIC'S IBRB SYSTEM
Susan M. Frank, Science Applications International Corp.
THE FOREIGN CORRUPT PRACTICES ACT AND THE ARMS EXPORT CONTROL ACT – ISSUES AT THE U.S. DEPARTMENT OF STATE
Dale C. Turza, Cadwalader, Wickersham & Taft LLP
FCPA ENFORCEMENT: DEALING WITH VIOLATIONS, DOJ & SEC INVESTIGATIONS AND PENALTIES
Joshua R. Hochberg, U.S. Department of Justice
FCPA ENFORCEMENT: DEALING WITH VIOLATIONS, DOJ & SEC INVESTIGATIONS AND PENALTIES
Stephen Preston, Wilmer Cutler Pickering Hale and Dorr
FCPA COMPLIANCE 2005 UPDATE: MANAGING FCPA RISKS
William F. Pendergast, Dickinson Landmeier LLP
OFAC COMPLIANCE STRATEGIES
John R. Pisa-Relli, U.S. Department of the Treasury
OFAC UPDATE & ISSUES
William B. Hoffman, Davis Polk & Wardwell
U.S. ANTIBOYCOTT COMPLIANCE
Janet Kim, Baker & McKenzie
ENSURING COMPLIANCE THROUGHOUT THE M&A PROCESS
Stephen Yslas, Northrop Grumman Corporation
ANTITRUST COMPLIANCE IN THE M&A PROCESS
Leon Greenfield, Wilmer Cutler Pickering Hale and Dorr
ASSET FORFEITURE & MONEY LAUNDERING SECTION
Lester Joseph, U.S. Department of Justice
DEFENSE TRADE IMPORTS – THE OTHER SIDE OF THE FENCE
Erin Crockett, Dresser, Inc.
THE SARBANES-OXLEY EFFECT: RECORD KEEPING, INTERNAL CONTROLS AND DISCLOSURE FOR DEFENSE COMPANIES
F. Joseph Warin, Gibson, Dunn & Crutcher
MITIGATING RISKS AND NAVIGATING INTERDEPENDENCIES
Kathy T. Humenik, The Boeing Company
AN INTEGRATED APPROACH TO DEFENSE INDUSTRY COMPLIANCE
Richard J. Bednar, Crowell & Moring LLP
DUE DILIGENCE AND COMPLIANCE PROCEDURES
Timothy L. Dickinson, Dickinson Landmeier LLP
OVERCOMING CHALLENGES IN DEEMED EXPORT COMPLIANCE
Richard Pettler, Fragomen, Del Rey, Bernsen & Loewy, LLP
Steve Brotherton, Fragomen, Del Rey, Bernsen & Loewy, LLP
James Bartlett, Northrop Grumman Corporation
Publication Details